IMP-1: Consider implementing Agency personnel into the CORE system – Learning Hub module.

TWMA uses agency personnel for additional work – as offshore operators. Their CVs are checked, and they get on the job training. Agency personnel are, as staffed personnel, checked and assessed during operations by Seniors, but this is not documented. The Audit team recommends TWMA to consider implementing Agency personnel into the CORE system/Learning Hub. The main reason for this is that if a contractor is offered a permanent position, TWMA does not have any documentation of the person’s experiences and the person concerned must start from scratch in the learning programme.

23.05.24: Agree with deadline but will be in touch if any additional time is needed. On initial review, the Learning Hub does not allow us to add and track third-party personnel, but we will review other ways of tracking and assessing competency in this area
24.06.24: We continue to review skills and competence through our agency training reviews ahead of selecting workers, as well as using people who have worked with us already. Further improvements are being reviewed to show competence on TWMA equipment for agency staff, but unfortunately our Learning Hub does not allow us to track this for non-TWMA employees as initially hoped. Please extend this by one month to match some other actions of the same date to allow us to finalise our review and implement any needed improvement.
26.07.24: Final review of our Learning Hub has concluded that we cannot add third-party personnel to the platform. We will continue to assess qualifications and competence requirements through our agency review processes whilst also assessing how best we can demonstrate and track this. It will remain a priority for us within our HSEQ and Training functions of TWMA.

IMP-2: Environmental aspects in operation needs to be assessed and highlighted for Falstaff.

Falstaff is located inside a very valuable area – sandeel area. Sandeel is a location-bound fish that is very dependent on the seabed and the correct grain size of the sand it lives in. The Falstaff license requirement is zero discharge of drilled cuttings, and TWMA is therefore contracted to handle cuttings from all sections and ensure a good handling on the rig, as well as having this transported to shore for proper handling. It is therefore extremely important for DNO that personnel are aware of the sensitivity in the area. The Audit team wants TWMA to secure that personnel offshore (the operators and seniors) know the environmental aspects associated with this type of operation. TWMA is ISO 14001 certified, and mapping of environmental aspect (elements of an organisation’s activities, products, or services that can interact with the environment), and determining the significant aspects, forms the basis for ISO 14001 Environmental Management. The Audit team therefor assumes that TWMA has good routines for such work.

23.05.24: Work is ongoing on this, and deadline seems to be sufficient time, but again, we will contact if we come across any issues with the close-out date.
24.06.24: We are on track for this to be completed as per proposed deadline – updates will be provided next month.
26.07.24: Further review completed for Norway Aspects & Impacts register considering the upcoming project with DNO / Well Expertise. See attached for latest copy dated 17.07.2024.

A-1: DNO to send presentation incl. findings and actions.

Presentation sent 16.04.24.

A-2: TWMA to send Risk, Opportunity & Contingency planning Management procedure.

Received 16.04.24.

A-3: TWMA to share Installation work pack.

23.05.24: Workpack will be sent when final scope is confirmed. Installation details were provided as part of the risk assessment but awaiting vessel survey to be completed. Suggest an extension to end of June.
24.06.24: On track – this will be provided end of June / beginning of July – please extend the due date to 12.07.2024 but should be available before this time
27.06.24: As we are still several weeks from install, the work pack has not yet been provided but will be sent as with standard project practices.
01.09.24: Received

A-4: DNO to send Discharge Permit Application.

Sent 03.05.24.

A-5: Send an overview of Scope 1, 2, and 3 when ready.

23.05.24: We are just waiting for the final actions to be completed to allow us to provide this which will likely be June so extended date suggested of end of June.
24.06.24: Draft report received 21.06.2024 and being reviewed internally – this can be provided once review is complete.
26.07.24: Received

A-6: Check if TWMA personnel need well control competence (IOGP 476).

16.04.24: TWMA has included IOGP 476 into Internal Compliance Legal Review as part of the 2024 Audit Schedule.
23.05.24: This aligns with our scheduled compliance internal audit review.
24.06.24: Reviewed by Group Training & Competency / Operational Management 11.06.2024: – On review, TWMA does not see the need for this to be introduced as no activities that our operations personnel take place has any effect in well control.

A-7: Consider joint SAR site assessment TWMA/DNO (June) or DNO observer (Anniken).

23.05.24: Proposed date of 07.06.2024 for the site visit – awaiting availability response from A. Meisler.
24.05.24: Anniken is joining 7th June
24.06.24: Site visit conducted 07.06.2024. Follow-up management system and process verification scheduled via Teams on 16.07.2024. Audit Report will be provided following this. Due date changed from 30.06.2024 to 31.07.2024.
26.07.24: From Sam: Communication sent 26.07.2024 – Awaiting access to MagnetJQS Audit to finalise Audit Report. SAR still to upload details to our vendor management system to allow for approval as recommended in critical vendor audit.
26.09.24: Report sent SAR from TWMA (Samantha Errington)

A-8: TWMA to provide job description and competency requirements for operator sand Senior Leads planned for the Falstaff well.

23.05.24: Once received from HR Job Descriptions can be sent on – Competency will follow [N McIntosh will be responsible for this].
24.06.24: Job Descriptions for Operator and Offshore Senior Lead roles received.

A-9: New mobilization on NINV need to be looked into, to secure new position of equipment, drain system, hose check, treatment of WBM, ergonomics (system works but non-bundled areas, hoses “in the way”, etc.).

23.05.24: Reviewed during risk assessment and will be included in the installation work pack which will be provided as per A-3.
24.06.24: Not due to 31.07.2024 – update will be provided.
05.09.24: Done

A-10: TWMA share experience in using PowerBI (meeting DNO).

23.05.24: Meeting with TWMA CORE Manager next week and will discuss the feasibility of this.
24.06.24: This can be arranged with Lindsey Macleod and myself (Samantha Errington) – please provide availability so a Teams call can be set up.
01.07.24: The action is now on Arild E. Lund (DNO), as TWMA is willing to share with DNO.
22.10.24: Asked Arild if this still is of interest, and answer was that this is no longer of interest as DNO is well into their PowerBI project. Action closed.

A-11: «Operational Information» (special attention to Augers, e-stop etc.) check list is ongoing. This Operator orientation form must be implemented on Falstaff.

23.05.24: «Operational Information» (special attention to Augers, e-stop etc.) check list is ongoing. This Operator orientation form must be implemented on Falstaff.
24.06.24: Checklist being finalised – will be provided on completion.
10.09.24: Check list ok and orientation form implemented

A-12: Changes of key personnel or suppliers must be reported to DNO DSI (Phil).

23.05.24: Operational checklist being drafted by HSEQ [Neil McIntosh and Scott McIntosh are responsible for this area].
There were no changes of personnel during the operation.

IMP-1: Consider implementing Agency personnel into the CORE system – Learning Hub module.

TWMA uses agency personnel for additional work – as offshore operators. Their CVs are checked, and they get on the job training. Agency personnel are, as staffed personnel, checked and assessed during operations by Seniors, but this is not documented. The Audit team recommends TWMA to consider implementing Agency personnel into the CORE system/Learning Hub. The main reason for this is that if a contractor is offered a permanent position, TWMA does not have any documentation of the person’s experiences and the person concerned must start from scratch in the learning programme.

23.05.24: Agree with deadline but will be in touch if any additional time is needed. On initial review, the Learning Hub does not allow us to add and track third-party personnel, but we will review other ways of tracking and assessing competency in this area
24.06.24: We continue to review skills and competence through our agency training reviews ahead of selecting workers, as well as using people who have worked with us already. Further improvements are being reviewed to show competence on TWMA equipment for agency staff, but unfortunately our Learning Hub does not allow us to track this for non-TWMA employees as initially hoped. Please extend this by one month to match some other actions of the same date to allow us to finalise our review and implement any needed improvement.
26.07.24: Final review of our Learning Hub has concluded that we cannot add third-party personnel to the platform. We will continue to assess qualifications and competence requirements through our agency review processes whilst also assessing how best we can demonstrate and track this. It will remain a priority for us within our HSEQ and Training functions of TWMA.

IMP-2: Environmental aspects in operation needs to be assessed and highlighted for Falstaff.

Falstaff is located inside a very valuable area – sandeel area. Sandeel is a location-bound fish that is very dependent on the seabed and the correct grain size of the sand it lives in. The Falstaff license requirement is zero discharge of drilled cuttings, and TWMA is therefore contracted to handle cuttings from all sections and ensure a good handling on the rig, as well as having this transported to shore for proper handling. It is therefore extremely important for DNO that personnel are aware of the sensitivity in the area. The Audit team wants TWMA to secure that personnel offshore (the operators and seniors) know the environmental aspects associated with this type of operation. TWMA is ISO 14001 certified, and mapping of environmental aspect (elements of an organisation’s activities, products, or services that can interact with the environment), and determining the significant aspects, forms the basis for ISO 14001 Environmental Management. The Audit team therefor assumes that TWMA has good routines for such work.

23.05.24: Work is ongoing on this, and deadline seems to be sufficient time, but again, we will contact if we come across any issues with the close-out date.
24.06.24: We are on track for this to be completed as per proposed deadline – updates will be provided next month.
26.07.24: Further review completed for Norway Aspects & Impacts register considering the upcoming project with DNO / Well Expertise. See attached for latest copy dated 17.07.2024.

A-1: DNO to send presentation incl. findings and actions.

Presentation sent 16.04.24.

A-2: TWMA to send Risk, Opportunity & Contingency planning Management procedure.

Received 16.04.24.

A-3: TWMA to share Installation work pack.

23.05.24: Workpack will be sent when final scope is confirmed. Installation details were provided as part of the risk assessment but awaiting vessel survey to be completed. Suggest an extension to end of June.
24.06.24: On track – this will be provided end of June / beginning of July – please extend the due date to 12.07.2024 but should be available before this time
27.06.24: As we are still several weeks from install, the work pack has not yet been provided but will be sent as with standard project practices.
01.09.24: Received

A-4: DNO to send Discharge Permit Application.

Sent 03.05.24.

A-5: Send an overview of Scope 1, 2, and 3 when ready.

23.05.24: We are just waiting for the final actions to be completed to allow us to provide this which will likely be June so extended date suggested of end of June.
24.06.24: Draft report received 21.06.2024 and being reviewed internally – this can be provided once review is complete.
26.07.24: Received

A-6: Check if TWMA personnel need well control competence (IOGP 476).

16.04.24: TWMA has included IOGP 476 into Internal Compliance Legal Review as part of the 2024 Audit Schedule.
23.05.24: This aligns with our scheduled compliance internal audit review.
24.06.24: Reviewed by Group Training & Competency / Operational Management 11.06.2024: – On review, TWMA does not see the need for this to be introduced as no activities that our operations personnel take place has any effect in well control.

A-7: Consider joint SAR site assessment TWMA/DNO (June) or DNO observer (Anniken).

23.05.24: Proposed date of 07.06.2024 for the site visit – awaiting availability response from A. Meisler.
24.05.24: Anniken is joining 7th June
24.06.24: Site visit conducted 07.06.2024. Follow-up management system and process verification scheduled via Teams on 16.07.2024. Audit Report will be provided following this. Due date changed from 30.06.2024 to 31.07.2024.
26.07.24: From Sam: Communication sent 26.07.2024 – Awaiting access to MagnetJQS Audit to finalise Audit Report. SAR still to upload details to our vendor management system to allow for approval as recommended in critical vendor audit.
26.09.24: Report sent SAR from TWMA (Samantha Errington)

A-8: TWMA to provide job description and competency requirements for operator sand Senior Leads planned for the Falstaff well.

23.05.24: Once received from HR Job Descriptions can be sent on – Competency will follow [N McIntosh will be responsible for this].
24.06.24: Job Descriptions for Operator and Offshore Senior Lead roles received.

A-9: New mobilization on NINV need to be looked into, to secure new position of equipment, drain system, hose check, treatment of WBM, ergonomics (system works but non-bundled areas, hoses “in the way”, etc.).

23.05.24: Reviewed during risk assessment and will be included in the installation work pack which will be provided as per A-3.
24.06.24: Not due to 31.07.2024 – update will be provided.
05.09.24: Done

A-10: TWMA share experience in using PowerBI (meeting DNO).

23.05.24: Meeting with TWMA CORE Manager next week and will discuss the feasibility of this.
24.06.24: This can be arranged with Lindsey Macleod and myself (Samantha Errington) – please provide availability so a Teams call can be set up.
01.07.24: The action is now on Arild E. Lund (DNO), as TWMA is willing to share with DNO.
22.10.24: Asked Arild if this still is of interest, and answer was that this is no longer of interest as DNO is well into their PowerBI project. Action closed.

A-11: «Operational Information» (special attention to Augers, e-stop etc.) check list is ongoing. This Operator orientation form must be implemented on Falstaff.

23.05.24: «Operational Information» (special attention to Augers, e-stop etc.) check list is ongoing. This Operator orientation form must be implemented on Falstaff.
24.06.24: Checklist being finalised – will be provided on completion.
10.09.24: Check list ok and orientation form implemented

A-12: Changes of key personnel or suppliers must be reported to DNO DSI (Phil).

23.05.24: Operational checklist being drafted by HSEQ [Neil McIntosh and Scott McIntosh are responsible for this area].
There were no changes of personnel during the operation.